Frequently Asked Questions

Medicaid and the Children’s Health Insurance Program (CHIP) can reimburse states for expenditures incurred by Local Education Agencies (LEAs)/school districts for the costs of administrative activities that support the provision of medical services covered under Medicaid or CHIP. Examples of allowable Medicaid and CHIP administrative activities can be found on page 75 of the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming. In general, some categories where administrative activities can fall include:

• Medicaid and CHIP outreach.
• Facilitating Medicaid and CHIP eligibility determinations.
• Transportation-related activities in support of Medicaid and CHIP services.
  • Note, when the State claims federal financial participation (FFP) for necessary transportation as an optional medical service, the State must not also claim the same transportation expenditures as an administrative activity, which would result in duplicative reimbursement.
• Translation and interpretation services related to covered services.
• Program planning, policy development, and interagency coordination related to Medicaid and CHIP.
• Medicaid- and CHIP-related training.
• Referral, coordination, and monitoring of Medicaid and CHIP services (distinct from case management activities covered as a medical service).

FAQ ID:162306

Yes, States are expected to apply the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming guidance to all MAC programs for all entities. Both previous guidance documents issued by CMS, including the 1997 School-based Services Technical Review Guide and the 2003 School-based Administrative Claiming Guide, are superseded by the 2023 Comprehensive Guide to Medicaid Services and Administrative Claiming.

FAQ ID:162336

First, the activities must be allowable as State program administrative activities. Secondly, the State and/or claiming unit must implement a methodology to properly identify and allocate Medicaid’s portion of cost associated with the allowable State program administrative activity. Finally, the identification and allocation of this cost must be documented in the State’s Public Assistance Cost Allocation Plan (PACAP). According to 45 C.F.R. § 95.517, State Medicaid agencies (SMAs) that intend to claim for allowable administrative activities must have an approved PACAP. As the PACAP is primarily used by the Federal cognizant agency to allocate cost incurred by one direct federal awardee, yet funded by another federal awardee, there may be instances where costs applicable to allowable State program activities are incurred and funded by the SMA. In this instance, the State may identify and allocate the cost via a Medicaid Administrative Claiming (MAC) Plan and include a reference to the identification and allocation of the cost via the MAC Plan in its PACAP.

FAQ ID:162321

CMS encourages SMAs to reimburse school districts their allowable costs of conducting Medicaid and CHIP administrative activities. School districts should work with SMAs to develop a plan to document their costs so that the SMA can distribute Medicaid and CHIP FFP to school districts in proportion to each district’s relative expenditures for Medicaid and CHIP administrative activities.

FAQ ID:162326

No, for the LTSS Comprehensive Care Plan and Update measure, the care plan does not have to take place in the member’s home. However, it must be done face-to-face unless certain exceptions are met. These exceptions include circumstances in which:

• The member was offered a face-to-face discussion and refused (either refused a face-to-face encounter or requested a telephone discussion instead of a face-to-face discussion).
• The state policy, regulation, or other state guidance excludes the member from a requirement for face-to-face discussion of a care plan.

FAQ ID:89146

Use the most recently updated care plan.

FAQ ID:89151

To meet the LTSS Comprehensive Care Plan and Update measure numerator, the care plan must be signed by the member, unless the care plan is under appeal in the specified timeframe, and there is documentation that the care plan was in appeal. There is an exclusion for members who refuse to take part in care planning. This exclusion is reported with the measure rate, so the overall measure rate can be interpreted correctly. For example, a plan that is not successful at engaging members in care planning, indicated by a high exclusion rate, would suggest the overall rate on the measure should be interpreted with caution.

FAQ ID:89166

There must be documentation that at least three attempts were made to reach the member, and they could not be reached. The rate of exclusion due to inability to reach a member should also be reported along with the measure performance rate.

FAQ ID:89176

In these circumstances, MLTSS plan records should clearly document that no caregiver was involved to satisfy the measure criteria. For example, there are situations in which it may not be appropriate to engage the caregiver, including cases in which the member refused to involve the caregiver, or the invited caregiver declined to participate. Reasons for lack of caregiver involvement are not required; documentation that a caregiver was not involved suffices.

FAQ ID:89181

For certain elements of the care plan, documentation of no deficit suffices to receive credit for the elements (for example, functional needs, medical needs, cognitive impairment needs). Other elements in the core and supplemental rates of the Managed Long Term Services and Supports (MLTSS) LTSS Comprehensive Care Plan and Update measure require documentation regardless of whether a deficit is identified (for example, individualized member goal, plan for follow-up and communication, plan for emergency). Refer to the details in the measure specification to identify where documentation of no deficit meets the element definition.

FAQ ID:89196